IRS Finalizes Schema for Automatically Exchanging FATCA Data with IGA Jurisdiction and Posts Frequently Asked Questions on FFI Lists to Web Site

The IRS announced that it has finalized the format for automatically exchanging FATCA data with countries that have entered into an Intergovernmental Agreement ("IGA") with the United States to exchange account information on accounts owned or held directly or indirectly by U.S. persons. According to the IRS, the Intergovernmental FATCA XML Schema (version 1.1), which was posted on the IRS FATCA web site on December 19, is a standard format developed in close cooperation with the OECD using elements from existing reporting schemas used by OECD and the European Union in order to reduce the burdens on reporting entities. This Schema will capture required information for reporting of FATCA data from both FFIs and Host Country Tax Administrations to facilitate a safe and secure electronic data transmission using the International Data Exchange Service. The IRS said that it also utilized XML to allow for easier modifications in the event of future legislative or regulatory changes in reporting rules.

Separately, on December 19, the IRS posted on the FATCA page on the IRS's web site a series of Frequently Asked Questions with respect to the FFI Lists that the IRS will begin publishing in 2014. The FFI Lists will be published monthly and will contain the name, Global Intermediary Identification Number ("GIIN") and country of residence or branch country of all Participating FFIs and all Deemed-Compliant FFIs. The FFI List is intended to be used by withholding agents to verify the status of financial institutions under FATCA. The FFI Lists will be published only in English and may be downloaded from the IRS's website by anyone with an internet connection. The IRS stated that it currently anticipates that the full FFI List will contain less than 500,000 FFIs.

Details with respect to the Intergovernmental FATCA XML Schema and FAQs re FFI Lists can be found at www.irs.gov/fatca. A copy of the FAQs is linked below.

See: FATCA FAQ; FATCA XML Schema.